On September 15, 2023, Canada released new sanctions under Schedule 1 of the Special Economic Measures (Iran) Regulations (the “Iranian Regulations”). The sanctions target six individuals for what Canada has identified as involvement in activities that constitute gross and systemic human rights violations.

Canada states that those targeted are connected to Iran’s Supreme Council for Cultural Revolution, the Islamic Revolutionary Guard Corps, and the Iranian parliament. These measures impose a dealings prohibition on the individuals, to freeze any assets they hold in Canada and bar their entry into Canada under the Immigration and Refugee Protection Act.

This round of sanctions come on the first anniversary of Mahsa Amini’s death, a young woman who died in police custody after being arrested for allegedly not properly wearing her hijab. Global Affairs Canada asserts that the sanctions are a response to the Government of Iran’s acceleration of surveillance and repression against its citizens, in particular women and girls.

Our team will continue to closely monitor the sanctions related to Iran, providing updates to keep clients informed about important developments affecting trade and services. We regularly assist with applications for exemption permits, including under the Special Economic Measures (Iran) Permit Authorization Order. We have significant experience in the design and implementation of sanctions-related compliance programs and internal investigations. Where breaches are identified, we work closely with clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada.

Authors: Vince DeRose, Jennifer Radford, Stephanie Desjardins, Michelle Folinas, Jack Bowness.

Should you have any questions regarding these developments or sanctions generally, please contact: